Epstein Secrets

(954) 356-0022 [email protected] Counsel for Plaintiflane Doe 1 STIPULATED AND AGREED TO BY: /s/John Butts John Butts Felicia H. Ellsworth WILMER CUTLER PICKERING HALE AND DORR LLP 60 State Street Boston, MA 02109 Tel: (617) 526-6687 Fax: (617) 526-5000 [email protected] [email protected]

York, New York 10001 May 2, 2023 The Honorable Christopher Wray Director Federal Bureau of Investigation Michael E. Horowitz Inspector General U.S. Department of Justice Washington, D.C. 20535 Washington, D.C. 20530 The Honorable Merrick B. Garland Attorney General U.S. De artment of ustice NW Washington, D.C.

s. • * • Pursuant to the Freedom of Information Act ("FOIA"), 5 U.S.C. § 552, 28 C.F.R. § 16.8, and any other applicable law. rule, or regulation, Wilmer Cutler Pickering Hale and Dort LLP requests on behalf of JPMorgan that confidential treatment be accorded to this letter (Bates numbered JPM-SDNY-CL-011-0001 through JPM

§ 552(b)(4), and the Trade Secrets Act, 18 U.S.C. § 1905, and will continue to remain exempt from mandatory disclosure even after the conclusion of the Department of Justice's ("Department") consideration of this matter. We note further that, since the Confidential Material constitutes investigatory records obtained by t

s. * * * Pursuant to the Freedom of Information Act ("FOIA"), 5 U.S.C. § 552, 28 C.F.R. § 16.8, and any other applicable law, rule, or regulation, Wilmer Cutler Pickering Hale and Don LLP requests on behalf of JPMorgan that confidential treatment be accorded to this letter (Bates numbered JPM-SDNY-CL-012-000l through JPM-

§ 552(bX4), and the Trade Secrets Act, 18 U.S.C. § 1905, and will continue to remain exempt from mandatory disclosure even after the conclusion of the Department of Justice's ("Department") consideration of this matter. We note further that, since the Confidential Material constitutes investigatory records obtained by t

l files. Accordingly, we are only producing the Excel files here. As discussed, we anticipate making further productions on a rolling basis. * * * Wilmer Cutler Pickering Hale and Dorr ttr, 7 World Trade Center, 250 Greenwich Street, New York, New York 10007 Beijing Berlin Boston Brussels Denver Frankfurt London Los

§ 552(b)(4), and the Trade Secrets Act, 18 U.S.C. § 1905, and will continue to remain exempt from mandatory disclosure even after the conclusion of the Department of Justice's ("Department") consideration of this matter. We note further that, since the Confidential Material constitutes investigatory records obtained by t

bered JPM-SDNY-CL-005-0001 through JPM-SDNY-CL-005-0009) and the referenced materials (Bates numbered JPM-SDNY-00003382 through JPM-SDNY-00054724 on JPM- Wilmer Cutler Pickering Hale and Dorr MP, 7 World Trade Center, 250 Greenwich Street, New York, New York 10007 Beijing Berin Boston Brussels Denver Frankfurt London LOS A

§ 552(bX4), and the Trade Secrets Act, 18 U.S.C. § 1905, and will continue to remain exempt from mandatory disclosure even after the conclusion of the Department of Justice's ("Department") consideration of this matter. We note further that, since the Confidential Material constitutes investigatory records obtained by t

ing email addresses that may have been associated with Mr. Epstein: [email protected]; [email protected]; and [email protected]. We Wilmer Cutler Pickering Hale and Dorr ue, 7 World Trade Center, 250 Greenwich Street, Ncw York, New York 10007 Beijing Berlin Boston Brussels Denver Frankfurt London Los

§ 552(b)(4), and the Trade Secrets Act, 18 U.S.C. § 1905, and will continue to remain exempt from mandatory disclosure even after the conclusion of the Department of Justice's ("Department") consideration of this matter. We note further that, since the Confidential Material constitutes investigatory records obtained by th

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